Serving as a member of the Standards Resource Commission created by the CFP Board to provide guidance to certified financial planners on compliance with the CFP Board's Code of Ethics and Practice Standards
Analysis of Securities and Exchange Commission's proposed "Regulation Best Interest" for securities broker-dealers
Memorandum on how bitcoin and other cryptocurrencies are regulated in the U.S.
Analysis of relevant prudent investment factors for fiduciary investments in stable value funds
Analysis of permissibility of ESG (environmental, social, governance) investing by fiduciaries in the United Kingdom
Client memorandum on whether an institutional money market fund is a prudent investment for fiduciary cash versus a government MMF
Analysis of class action lawsuits alleging violations of ERISA by university pension plans
Series of papers on how robo-advisors are regulated, how they should be regulated, and whether they are "fiduciaries"
Paper discussing comparative risk and reward features of different types of cash sweep programs offered by broker-dealers, comparing deposit sweeps with MMF sweeps
Analysis of "robo-advisor" service structures, fee arrangements, and potential conflicts of interest
Analysis of Department of Labor fiduciary rule under ERISA and its application to regulated broker-dealers
Banking law expert in international Investor-State Dispute Settlement (ISDS) case
Analysis of legal issues raised by third party vendor relationship with bank under Bank Service Company Act and bank supervisory guidance
Analysis of eligibility of trust accounts to invest in retail money market funds
Client memorandum analyzing the extent to which cost is a component of the duty of prudence that must be considered by a fiduciary when investing fiduciary assets
Analysis of SEC final regulation on money market fund reform
Client memorandum re authority of Financial Stability Oversight Council and Federal Reserve to designate and regulate nonbank "SIFIs"
Request to Federal Reserve requesting ruling that certain government-only money market funds are "highly liquid assets" for purposes of large bank liquidity requirements
Analysis of Federal Reserve regulation adopting prudential standards for large bank SIFIs
Comment letters on SEC proposal to change regulation of money market funds
Research and analysis concerning regulation of money market funds
Client memorandum on fiduciary duties with respect to underperforming assets
Comment letters to FDIC and Federal Reserve Board concerning Reglation Q repeal
Analysis of Regulation D definition of "deposit" in connection with sweep arrangement
Paper on implications of financial crisis for modern portfolio theory and Uniform Prudent Investor Act
Letter to FASB concerning treatment of money market funds as cash equivalents for financial statement reporting purposes
Comment letter on SEC proposal regarding regulation of municipal advisors
Analysis of SEC study on treatment of securities brokers as fiduciaries
Conceptualizing proposal for regulatory treatment of principal trades by broker-dealers
Analysis of regulatory criteria for designation of nonbank financial companies as "systemically important"
Analysis of Volcker Rule restrictions on proprietary trading and hedge fund activities by banking entities
Analysis of proposals by Financial Stability Oversight Council
Analysis of issues relating to "shadow banking system"
Comment letter on Moody's proposal to revise rating criteria for money market funds
Analysis of President's Working Group recommendations on money market funds
Comment letter on FDIC proposal to extend guarantee of noninterest bearing transaction accounts
Analysis comparing broker-dealer suitability standard with trustee fiduciary standard
Analysis of SEC proposal to revise Rule 12b-1 mutual fund fees
Paper on implications of Dodd-Frank Act for bank holding companies
Analysis of various titles of Dodd-Frank Wall Street Reform and Consumer Protection Act
Paper analyzing the reasonableness standard for service provider fees under the Employee Retirement Income Security Act (ERISA)
Drafting legislative amendments to financial services reform legislation
Analysis of new Basel international liquidity framework for banks
Analysis of financial reform legislation
Analysis of implications of new consolidated accounting rules (FAS 167) for bank capital
Advice regarding FINRA rules on "parking" of brokerage license and applicability of certain FINRA rules to bank employees engaged in securities transactions
Analysis of proposed Investor Protection Act of 2009 and related proposals
Analysis of legislation proposed by Obama Administration to reform the financial regulatory system
Advice for securities brokers on implications of fiduciary status under Investment Advisers Act of 1940
Analysis of Administration proposal to impose a fiduciary duty on securities broker-dealers
Analysis of Financial Accounting Standards Board issuance on consolidated accounting (FAS 167) and implications for money market mutual funds
Memorandum analyzing Treasury proposal to establish a regulatory mechanism for resolving failing financial companies
Memorandum on meaning of "systemic risk" and proposals to address systemically significant financial institutions
Memorandum on Federal Reserve systemic oversight authority under "umbrella" regulation provisions of Gramm-Leach-Bliley Act
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